AML & KYC policy

Our regulatory posture

Coynitt Canada Inc. is incorporated in Alberta and has submitted its FINTRAC Money Services Business (MSB) registration application; that registration is currently in review. We comply with the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and the regulations made under it.

Identity verification (KYC)

Every Coynitt user must complete identity verification before sending or receiving money. We use Sumsub — a regulated identity verification partner used by Coinbase, Wealthsimple, and dozens of other Canadian fintechs — to verify:

• Government-issued photo ID (passport, driver's licence, or PR card).
• A live selfie matched to the ID.
• Canadian residency address.
• Date of birth (you must be 18+).
• Source of funds.
• Politically Exposed Person (PEP) status.

Transaction monitoring

Every transaction is screened in real time for:

• Sanctioned individuals or jurisdictions (OFAC, UN, EU, OSFI).
• Unusual amounts or patterns relative to the user's history.
• Velocity (rapid sequential transfers).
• Geographic and corridor risk indicators.
• Known fraud patterns (stolen accounts, mule activity).

Reporting obligations

Where required by law, we file:

• Suspicious Transaction Reports (STRs) when we have reasonable grounds.
• Large Cash Transaction Reports (LCTRs) for cash deposits ≥ CAD $10,000 (note: Coynitt does not currently accept cash, so LCTR filings are typically nil).
• Electronic Funds Transfer Reports (EFTRs) for international transfers ≥ CAD $10,000.
• Terrorist Property Reports when triggered.

Record retention

We retain identity verification records, transaction records, and compliance documentation for five years after the customer relationship ends, in accordance with PCMLTFA requirements.

Compliance officer

A designated Compliance Officer is responsible for our AML program, training, ongoing risk assessment, and reporting. Concerns or questions can be sent to compliance@coynitt.ca.

Prohibited transactions

Coynitt cannot be used to send funds to or from sanctioned jurisdictions, sanctioned individuals, or for any unlawful purpose. Attempts to circumvent our controls will result in account closure and, where required, regulatory reporting.